5.0 Optimizing Aircraft and Production Certification Commercial UAS aircraft and production certification remains largely a specialized activity conducted by only a small number of organizations in the United States.57 In contrast, thousands of Part 107 waivers and Section 44807 (legacy Section 333) exemptions have been submitted to the FAA. As a result, certification activities do not lend themselves to statistical analysis through surveys. Information in this section was informed by existing literature and interviews with leading industry UAS program management and development executives with experience in leading certification initiatives for their organizations. General Observation from Interviews The FAA continues to view UAS certification through the lens of manned aviation. This translation process of one set of requirements to another needlessly impedes certification.58 Across the board, interviewees believe that the FAA provides inadequate guidance on UAS certification.59 Flight Testing In the certification process the Original Airworthiness Certificate for aircraft and/or UAS is issued by the FAA Manufacturing Inspection District Offices (MIDO). An experimental certificate to allow for research and development is good for one year after the date of issue or renewal, unless a shorter period is deemed necessary. Order 8130.34d allows Airworthiness Aviation Safety Inspectors (ASIs) from Flight Standards District Offices (FSDOs) to issue recurrent certifications. Multiple interviewees perceive that there might be reluctance for FSDOs to take on this activity. FAA continues to treat UAS certification programs as they would for full type certification of an aircraft and not certification of an experimental aircraft for test purposes. In general, the Product Certification process used by UAS was originally intended for a Part 25 large commercial transport category aircraft. Despite complaints about having to navigate the existing certification processes, interviewees in general felt that the processes in place for giving and receiving feedback to the FAA works well. But vehicle manufacturers experience a greater than expected re-assignment and turnover of FAA oversight personnel. Assignments are viewed as being “ad hoc� in nature which often results in the wrong set of skills brought to the position by the FAA representative.60 Components and Subsystems UAS systems developed and accepted through Department of Defense (DOD) processes often contain components designed to military specifications (MILSPEC).61 However, differing standards between MIL-SPEC components and FAA approved parts impedes transitioning military systems to civil use. Converting such
Bridging the Gap: Sustaining UAS Progress with Pursuing a Regulatory Framework
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